Process Safety and Major Hazard Policy

Purpose. States the commitment of Hydra to preventing major accidents at its major hazard facility and sets out the framework of controls that the safety case relies on.

1.Policy statement

Hydra will operate its plants so that hazardous chemicals remain contained and major accidents are prevented. The Site General Manager is accountable for the safety case and for ensuring that every control measure it describes is in place, functioning and maintained. Process safety takes precedence over production, cost and schedule in every decision.

2.Major accident hazards

The safety case identifies the major accident events that the Kwinana plant and the terminal are capable of, and the control measures that prevent or mitigate each one. Every worker must know the major accident hazards for their area and the controls that they are personally responsible for.

• Loss of containment of hydrochloric acid or ferric chloride releasing a toxic vapour cloud
• Loss of containment of flammable solvent leading to a pool fire or vapour cloud explosion
• Runaway reaction or overpressure in a batch reactor
• Mixing of incompatible chemicals during transfer or storage
• Tank overfill at the terminal during ship or tanker receipt
• Loss of firewater or bund integrity during an emergency

3.Control measures

Control measures are engineered, procedural and organisational. Safety critical equipment is listed in the register and must be inspected, tested and maintained to the schedule the safety case commits to. Procedures for start-up, shutdown, transfer and abnormal situations must be followed as written. Competence for every safety critical role must be assessed and recorded before a person works unsupervised.

4.Management of change

No change to plant, chemicals, control systems, procedures, staffing levels or organisation will be made without a management of change review that assesses the effect on the safety case and its control measures. Temporary changes must have an expiry date and must be reversed or made permanent through the same process.

5.Learning from events

Every loss of containment, activation of a safety system, exceedance of a safe operating limit, alarm flood and near miss must be reported and recorded as a process safety event. Events will be investigated to the depth their potential severity warrants and the learning will be shared across shifts and with the regulator where required.

6.Performance monitoring

Process safety performance indicators covering leading measures such as safety critical equipment testing, permit audits and overdue actions and lagging measures such as loss of containment events will be reported monthly to the site leadership team and quarterly to the board.

7.Review

This policy will be reviewed annually and whenever the safety case is revised, a major accident or serious near miss occurs or legislation changes.